ELD Mandate Frequently Asked Questions
What is the ELD mandate?
The Electronic Logging Device (ELD) mandate is the common name for a comprehensive final rule published by the Federal Motor Carrier Safety Administration (FMCSA) on December 16, 2015, in the Federal Register. The e-log mandate sets who must use electronic logging devices, the required technical standards of ELDs, new supporting document requirements, and prohibition from driver harassment using the information from an ELD device.
When does the e-log mandate take effect?
The ELD mandate requires the use of a compliant electronic log, either an automatic onboard recording device, (AOBRD), or an electronic logging device, by all interstate drivers of commercial motor vehicles (CMVs) to record their hours of service (HOS) who are currently required to log and who are not otherwise exempt as of December 18, 2017. AOBRDs installed before December 18, 2017, can be used until December 16, 2019, by which time they must be upgraded to the ELD technical specifications.
Do I need to comply with the electronic logs mandate?
The electronic logging rule applies to most motor carriers and drivers who are currently required to maintain records of duty status (RODS) per 49 CFR 395.8(a). The rule applies to commercial buses as well as trucks, and to Canada- and Mexico-domiciled drivers while operating in the United States.
Who will be exempt from having to use ELDs?
Specific ELD exemptions exist for:
- Drivers who only had to log 8 days (or fewer) out of the last 30 days
- Drivers operating a driveaway/towaway vehicle that is part of a delivery
- Drivers driving or towing a recreational vehicle in a driveaway/towaway operation
- Drivers operating a vehicle that is older than model year 2000 (1999 or older) or that has an engine that is older than model year 2000 in certain circumstances (such as a “glider kit” or a vehicle that has had an engine replacement)
- Drivers operating a rental truck that was rented under the terms of a lease agreement that is 8 days or less in duration
In addition, there are short-term waivers in place that allow small groups of drivers to continue using paper logs. Also, drivers that are fully exempt from the HOS rules due to using one of the exceptions in §390.3, §390.23, or §395.1 (government employees, drivers transporting agricultural commodities within 150 miles of the source, drivers operating utility service vehicles, etc.) are also exempt from using an electronic logging device while operating in the covered exempt capacity.
What are the key requirements of the ELD mandate?
The electronic logs mandate:
- Requires use of either automatic onboard recording devices (AOBRDs) or electronic logging devices (ELDs) by most commercial drivers who are required to prepare hours-of-service records of duty status.
- Sets performance and design standards for ELDs, and requires devices to be certified and registered with FMCSA.
- Establishes what supporting documents drivers and carriers are required to keep.
- Prohibits harassment of drivers based on ELD data or connected technology (such as fleet management system). The rule also provides recourse for drivers who believe they have been harassed.
Is there a reason to use ELDs even if the e-log mandate doesn’t require me to?
From an electronic logging perspective, even if the company is exempt, they may choose, as a good business decision, to use an ELog solution that enables the carrier to:
- Effectively manage complex Hours of Service requirements
- Know where their assets are
- How safely the assets are being operated
- Have the ability to estimate time to a job site and time back to the terminal
- Manage productivity (time at a job site, stopped, traveling, out-of-route travel, etc.)
- Document driver vehicle inspections
- Track driver qualifications
- Track vehicle maintenance
- Create a performance incentive program based on quantifiable data
- Have a tool that assists with IFTA and IRP compliance